Oneclick, LLC

Privacy policy

1. Definitions and Interpretation

1.1. We - OneClick Airways JSC.
1.2. You - any individual (other than crew members) transported on an aircraft under a valid Ticket – "Passenger".
1.3. Personal data (‘data’) - any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, including by his/her name, surname, identification number, location data and electronic communication identifiers, or by physical, physiological, mental, psychological, genetic, economic, cultural or social characteristics;
1.4. Special categories of data - data connected to a person’s racial or ethnic origin, political views, religious, philosophical or other beliefs, membership of professional unions, health, sexual life, status of an accused, convicted or acquitted person or a victim in criminal proceedings, conviction, criminal record, diversion, recognition as a victim of trafficking in human beings or of a crime under the Law of Georgia on the Elimination of Violence against Women and/or Domestic Violence, and the Protection and Support of Victims of Such Violence, detention and enforcement of his/her sentence, or his/her biometric and genetic data that are processed to allow for the unique identification of a natural person;

2. Applicability and Jurisdiction

2.1. This policy governs how we process your personal data whenever you interact with us as either an existing or potential customer. It extends to a variety of circumstances, including travelling on our flights, accessing our digital channels (such as mobile applications or websites), reaching out to our customer service teams or call centres, and arranging bookings with us directly or through intermediaries like airlines or travel agencies.

2.2. We process personal data solely when there is a lawful basis for doing so, as established under Georgian legislation—primarily the Law of Georgia on Personal Data Protection, along with any other applicable legal provisions.

2.3. All matters relating to the transfer and processing of personal data within our relationship are governed by the legislation of Georgia.

3. Purposes of Processing Personal Data and Who We Share Your Information With

3.1. We process your personal information for several purposes, including:

  • 3.1.1. Confirming your booking, issuing travel documents, and making any necessary adjustments to your reservation;
  • 3.1.2. Arranging and fulfilling your travel, including check-in, carriage of you and your baggage, and related ground-handling services;
  • 3.1.3. Carrying out required procedures such as security checks, customs, and border control;
  • 3.1.4. Assisting with baggage tracing and facilitating flight connections at airports;
  • 3.1.5. Providing you with information about ticket offers and additional services you may be interested in;
  • 3.1.6. Meeting our legal and regulatory obligations;
  • 3.1.7. Protecting your vital interests or those of another person where necessary;
  • 3.1.8. Pursuing our legitimate interests as an airline and travel provider, such as operating, maintaining, and improving our services;
  • 3.1.9. Promotional activities conducted by us and our partners;
  • 3.1.10. Processing your data for specific purposes where you have granted us consent.
  • 3.1.11. We may share your personal information with certain parties to provide our services and better understand your requirements.
  • 3.1.12. Other cases where it is not prohibited by law and is necessary to enhance the effectiveness of our operations or for another legitimate purpose.
  • 3.1.13. No data will be shared without your consent where the law requires it.

3.2. We may share your personal information:

  • 3.2.1. Within our corporate group: Companies within our group may access your data to help deliver services and enhance your experience. Marketing communications will only be sent if you have explicitly consented.
  • 3.2.2. Government and regulatory authorities: We may provide your information to customs, immigration, and other governmental bodies in any country on your travel itinerary, including stopovers or overflown countries, as required by law.
  • 3.2.3. Airlines and other service providers: When your travel includes flights, car hire, or hotel bookings arranged through third parties, we may share the necessary information to ensure the services you requested are delivered. These providers are identified when you make your booking.
  • 3.2.4. Payment processing and fraud prevention: Credit and debit card companies, credit reference agencies, and anti-fraud service providers may process your payment information and assist in detecting or preventing fraud.
  • 3.2.5. Legal and law enforcement requests: We may disclose your information in response to valid legal requests or to comply with judicial, governmental, or regulatory requirements.
  • 3.2.6. Service providers: Third-party companies acting on our behalf may process data for operational purposes, including running marketing campaigns, conducting customer surveys, or other business functions.
  • 3.2.7. Enforcing rights: Law firms, courts, police, and regulatory authorities may receive your information to enforce contracts, protect our rights, property, or the safety of our customers, staff, and assets.
  • 3.2.8. Marketing and analytics: We may provide usage data, including personal information where applicable, to marketing agencies or other websites to deliver targeted advertising or analyze website traffic.
  • 3.2.9. Compliance with legal or regulatory obligations: We may share information when necessary to fulfill legal or regulatory duties, including obligations arising from voluntary operational decisions, such as choosing to operate in a particular jurisdiction.
  • 3.2.10. No data will be shared without your consent where the law requires it.

4. Data Controller and Security Measures

4.1. Any personal information processed under this Privacy Policy is managed by Oneclick Airways JSC, which acts as the “data controller” of your information in accordance with the Legislation;

4.2. Security Measures: To ensure the security and confidentiality of your personal data, we implement a comprehensive set of technical and organizational measures in accordance with applicable data protection laws and industry best practices. These measures include, but are not limited to, a secure data storage infrastructure, encryption of data during transmission and storage, strict access control and authentication procedures, ongoing system monitoring, and regular security assessments aimed at preventing unauthorized access, disclosure, modification, or destruction of personal data.

5. Consent

You have the right to withdraw any consent you have previously given for the processing of your personal data at any time, however withdrawing your consent only affects future processing. It does not affect the legality of any data processing carried out before your withdrawal. In some circumstances, we may still be legally permitted to continue processing your personal information on a different basis, such as to fulfill contractual obligations.

6. Contact

If you experience difficulties withdrawing your consent through our website, or any other Personal Data matters please reach out to us at [email protected].